2023 Program Requirements

In the fall of 2022, CMS finalized changes to the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals (CAHs) for calendar year (CY) 2023. These changes and requirements can be found below.

For information on Hardship Exceptions and Payment Adjustments, please visit the Medicare Promoting Interoperability Program Resource Library.

EHR Reporting Period in CY 2023

The Electronic Health Record (EHR) reporting period for new and returning participants attesting to CMS is a minimum of any continuous, self-selected, 90-day period.

Certified EHR Technology (CEHRT)

To be considered a meaningful user and avoid a downward payment adjustment, eligible hospitals and CAHs attesting to the Medicare Promoting Interoperability Program will be required to use CEHRT that has been updated to meet 2015 Edition Cures Update criteria.

The CY 2023 CEHRT requirements for the Medicare Promoting Interoperability Program are as follows:

• 2015 Edition Cures Update functionality must be used as needed for a measure action to count in the numerator during the EHR reporting period chosen by the eligible hospital or CAH (a minimum of any continuous 90 days in 2023).
• In some situations, the product may be deployed during the EHR reporting period but pending certification. In such cases, the product must be updated to the 2015 Edition Cures Update criteria by the last day of the EHR reporting period.
• Eligible hospitals and CAHs must provide their EHR’s CMS Identification code from the Certified Health IT Product List (CHPL), available on HealthIT.gov, when submitting their data.

To learn more about the 2015 Edition Cures Update, please review ONC’s 21^st Century Cures Act Final Rule and the ONC Certification Criteria webpage. To check whether a health IT product has been updated to the 2015 Edition Cures Update, visit the Certified Health IT Product List (CHPL) at https://chpl.healthit.gov/.

Objectives and Measures

Participants are required to report on four scored objectives and their measures.

1. Electronic Prescribing
2. Health Information Exchange
3. Provider to Patient Exchange
4. Public Health and Clinical Data Exchange

Participants are also required to report (yes/no) on the Protect Patient Health Information objective:

• Security Risk Analysis measure
• Safety Assurance Factors for EHR Resilience (SAFER) Guides measure

Scoring Methodology

CMS continues to implement a performance-based scoring methodology. Each measure will contribute to the eligible hospital or CAH’s total Medicare Promoting Interoperability Program score. A minimum of 60 points is required to satisfy the scoring requirement.

Electronic Clinical Quality Measures (eCQMs)

Must report on the following using 4 self-selected quarters of data:

• 3 self-selected eCQMs; AND

The Safe Use of Opioids Concurrent Prescribing eCQM